From the FDA docket on preventive food safety controls for fresh produce comes highlights of comments submitted by the Northwest Horticultural Council.
We thank the Center for Food Safety and Applied Nutrition of the Food and Drug Administration (FDA) for the opportunity to share information on the tree fruit industry of the Pacific Northwest and to comment on the development by FDA of possible food safety standards for fresh produce at the farm and packinghouse. Also, our thoughts on cooperative efforts to ensure compliance with such standards, if developed, are being provided.
Role of the good agricultural practice guidelines entitled “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables”:
The “Guide” has become the foundation document for the food safety plans followed by our growers and packers. We find it sound, useful in practice, pragmatic, and understandable. The “Guide” should be retained by FDA as the lead document for those growing and packing fresh fruits and vegetable crops that are not deemed to be of any heightened food safety concern. An actual risk profile indicating the clear public need for the imposition of stricter standards should be required before they are imposed on a specific produce crop.
Standards for domestic and foreign growers and packers:
No federal regulatory food safety standard should be imposed by FDA on American produce growers and packers unless clearly necessary to protect the public health. When such a risk finding—based on a valid scientific assessment—is made, then both domestic and imported foreign product should be subject to the same standard.
However, in terms of fresh fruits and vegetables grown in foreign lands, any risk prevention standard or system would be extremely difficult for FDA to supervise or enforce given the overall
size of the global fresh produce market; its scattered production areas; multitude and diversity of growers; and, the lack of overseas resources at FDA. We would be skeptical about achieving the successful implementation of any required FDA food safety standard for imported produce, especially if grown in Asia, Africa or parts of the less developed world.
Two additional factors tied to this subject this should be considered by FDA: (1) the economic cost to domestic industry of implementing a given food safety measure and the competitive disadvantage that results if that same standard is not implemented and resulting costs absorbed by foreign competitors, and (2) the real risk that governments in current foreign markets for U.S. produce will demand their own on-site inspections and adherence to local food safety rules for produce grown in the United States but shipped abroad. This would result in higher costs and possible export market closures.